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IRB 2009-47

Table of Contents
(Dated November 23, 2009)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2009-47. Click on an entry to view the entry. Items shown under "Highlights of This Issue" open summaries of each IRB-referenced document only. Scroll to Parts I, II, etc. to view the full text versions of each IRB-referenced document. Use the "Keyword Search" option of TouchTax to search the full text of all Internal Revenue Bulletins, including this IRB.

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Highlights of This Issue

These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

2009 base period T-bill rate. The “base period T-bill rate” for the period ending September 30, 2009, is published as required by section 995(f) of the Code.

Proposed regulations under section 1563 of the Code clarify which corporations are included in a controlled group of corporations. The regulations clarify that a corporation that satisfies the controlled group rules for stock ownership and qualification is a member of such group, without regard to its status as a component member.

EMPLOYEE PLANS

Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in November 2009; the 24-month average segment rates; the funding transitional segment rates applicable for November 2009; and the minimum present value transitional rates for October 2009.

EXEMPT ORGANIZATIONS

Proposed regulations under section 509 of the Code, required by the Pension Protection Act of 2006, provide rules for supporting organizations that are operated “in connection with” their supported organization(s) (called “Type III supporting organizations”). The proposed regulations specify the information that Type III supporting organizations are required to provide their supported organizations. The proposed regulations also provide the criteria that Type III supporting organizations must satisfy in order to qualify as “functionally integrated.” For those Type III supporting organizations that do not qualify as functionally integrated, the regulations require an annual payout equal to five percent of the fair market value of the organization’s non-exempt use assets, a payout requirement modeled on that imposed on private foundations under section 4942.

EXCISE TAX

Proposed regulations under section 509 of the Code, required by the Pension Protection Act of 2006, provide rules for supporting organizations that are operated “in connection with” their supported organization(s) (called “Type III supporting organizations”). The proposed regulations specify the information that Type III supporting organizations are required to provide their supported organizations. The proposed regulations also provide the criteria that Type III supporting organizations must satisfy in order to qualify as “functionally integrated.” For those Type III supporting organizations that do not qualify as functionally integrated, the regulations require an annual payout equal to five percent of the fair market value of the organization’s non-exempt use assets, a payout requirement modeled on that imposed on private foundations under section 4942.

ADMINISTRATIVE

Proposed regulations under section 6501 of the Code relate to the exception to the general three-year period of limitations on assessment under section 6501(c)(10) for listed transactions that a taxpayer failed to disclose as required under section 6011.



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